Armature Group, Inc.
The Armature Group Privacy Shield Policy outlines the privacy practices that we implement for Personal Data received from the EEA and UK in reliance on the Privacy Shield. The Privacy Shield Framework uses the terms defined below:
“Personal Data” and “personal information” are data about an identified or identifiable individual that are within the scope of the Directive received by an organization in the
United States from the EEA or UK and recorded in any form.
“Processing” of personal data means any operation or set of operations that may be performed on personal data, automated or otherwise—such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of processing of personal data.
Due to the nature of its business, Armature Group is, at times, both the Controller and the Processor of personal information. This Policy describes the information we collect in the normal course of business and from whom. It describes how we use the information as well as how long we retain it. The collection of and processing of personal information of our respondents follows the Privacy Shield Framework Principles as described in this policy.
Types of Data We Collect:
At Armature Group, we collect personal data in order to conduct Market Research on behalf of clients in the pharmaceutical and biotechnology industries. We collect only the Personal information required to perform the specific research tasks related to the study or studies we are conducting.
The types of personal data that we collect include:
Contact details (name, title, address, email)
Employer (if pertinent) and/or medical specialty
Telephone and/or fax numbers
Certain health data as needed
At times, special circumstances may require explicit and/or additional consent from our respondents. For example, we obtain explicit consent for video and audio recordings of interviews and focus groups.
If adverse events are revealed during the course of data collection, additional consent is requested and the relevant information sent to our client per its standard protocols.
Methods of Data Collection
Armature Group’s methods of collecting data include:
Telephone or videoconference (e.g., FocusVisions’s InterVuTM) interviews
In person interviews, dyads, triads, and focus groups
Online bulletin boards (OLBBs)
Respondents are advised at the time of their initial consent and again at the start of their interview session that others affiliated with the research may monitor or view recordings of the data collection process, but that Armature will make efforts to keep their responses anonymous and confidential.
Purpose of Collecting Personal Data:
Armature Group collects and processes personal information solely for the purposes of executing the primary market research studies it has been commissioned to complete. Our reports and presentations to clients feature aggregated and/or blinded results so that no individual respondent can be associated with his/her opinions. Armature excludes all personally identifiable information (PII) from items shared with its clients and, whenever possible, avoids collecting it altogether.
Retention of Information:
We retain personal information only for 90 days after conclusion of its associated study, at which point the information is removed from our systems. The lone exception to this policy is when adverse events are reported during the course of data collection. In this circumstance, we may retain the information for up to 10 years as required by binding agreements with the end client. If no concrete policy exists
for retention of adverse event data, Armature will delete it along with any other PII accumulated over the course of the study.
Transfer of Data:
In the course of its usual and customary business, Armature Group will occasionally require transfer of data from the EEA and/or UK. When so doing, it will observe the same degree of protection or greater with regard to personal information.
Anyone concerned about Armature’s use of their Personal Information may contact Armature Group via email at firstname.lastname@example.org or by telephone at 1-484-413-2024 with any inquiries or complaints. Physical mail may be addressed to Dr. Sally Davis, President, Armature Group Inc., 308 East Lancaster Avenue, Suite 215, Wynnewood, PA, 19038.
Third Party Service Providers:
The following tasks are routinely performed for Armature by a number of third party service providers: Transcription, translation, and recruitment of market research participants, preparation of cross-tabs, and statistical analysis and support.
Our third party service providers are required to take appropriate security measures to protect personal data that are in line with our security policies.
We include standard contractual clauses in our contracts with third party service providers that include agreed upon confidentiality and security expectations.
All respondents to the studies that Armature conducts have the following rights with respect to their personal information:
The right to request access to their information. They are entitled to a copy of the personal information that we hold and to confirm that we are lawfully processing it.
The right to request a correction to the information that we hold. This allows them to correct any incomplete or incorrect information.
The right to request erasure of their personal information. They may ask to have it deleted or removed in the event that they no longer want their information processed as part of the study.
The right to refuse, restrict, or suspend the processing of their personal information
The right to opt out of any recording or additional listeners during an interview.
The right to invoke binding arbitration under certain conditions.
To Process this Request:
There are no fees or other hidden costs for a respondent to request their personal information or to exercise their rights with respect to their information.
Armature may request further specific information to help confirm the respondent’s identity to ensure their rights to the specified information in question.
Respondents have the right to withdraw their previously provided consent for the specific processing purpose at any time.
Accountability and Dispute Resolution:
Armature Group is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, Armature Group, Inc. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Armature Group, Inc. at:
Sally Davis, President: 484-413-2022, email@example.com
Judi Schettler, Operations Manager: 484-414-4028, firstname.lastname@example.org
Armature Group, Inc. has further committed to refer unresolved complaints under the EU-US Privacy Shield Principles to INSIGHTS ASSOCIATION PRIVACY SHIELD PROGAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.
On its Web site, Armature Group will publish the procedures for verifying compliance and responding to complaints regarding potential deviations from its established procedures for protecting Personal Information.
Armature Group, Inc. will, under certain circumstances, when permitted or required by law or court order, collect, use and/or disclose Personal information pursuant to procedures that do not require giving notice or conducting related activities (e.g., in connection with law enforcement investigations.
Armature Group, Inc. maintains its liability in cases of onward transfers to third parties.